SCOTT v. C.I.R.

No. 99-9018.

236 F.3d 1239 (2001)

Thomas H. SCOTT and Lynn D. Scott, Transferees, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

January 4, 2001.


Attorney(s) appearing for the Case

Thomas G. Hodel of Doussard Hodel & Markman, P.C., Lakewood, Colorado, for Petitioners-Appellants.

Joel McElvain, Attorney (Ann B. Durney, Attorney, with him on the brief), Tax Division, Department of Justice, Washington, D.C., for Respondent-Appellee.

Before LUCERO, McKAY, and MURPHY, Circuit Judges.


McKAY, Circuit Judge.

The Tax Court determined that Petitioner-Appellant Thomas H. Scott,1 who was a corporate executive of a now insolvent company, was liable as a transferee of assets for unpaid income taxes and the interest that accrued since the taxes became due. Appellant asserts that he cannot be a transferee within the meaning of 26 U.S.C. § 6901(a)(1)(A) because he did not directly receive any assets from the assessed company...

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